Call for EPA to Protect Bt
The U.S. Environmental Protection Agency (EPA) is holding a
hearing on March 21, 1997, in Washington DC, to examine the
resistance management plan implemented last summer for Bt
cotton. This hearing is an opportunity for the organic and
sustainable agriculture communities to tell EPA that it is
not doing enough to protect the effectiveness of Bascillus
thuringiensis (Bt) as a pest management tool.
Bt crops are transgenic plants genetically engineered to
produce Bt toxins, which occur naturally in soil bacteria.
Spray preparations of bacteria containing the toxin have been
used for decades by organic growers and other sustainable
agriculture practitioners. This past season, three Bt crops
- -- corn, cotton, and potato -- were grown on a large scale
for the first time in the U.S.
Scientists agree that widespread use of Bt crops threatens
the continued effectiveness of Bt by accelerating the
evolution of insect resistance to the toxin. Once insects are
resistant, Bt sprays and Bt crops will be ineffectual in
controlling insect pests. To attempt to delay the development
of resistance, EPA, under pressure from environmentalists and
organic farmers, has required that Bt resistance management
plans be implemented with Bt cotton and Bt corn.
At issue in the March 21 hearing is whether EPA-approved
resistance management plans will work. For example, the Bt
cotton plan relies on the cotton plant to produce a high
enough dose of the toxin that all but the most highly
resistant cotton bollworms will perish. In addition, plans
call for using refuges -- stands of non-Bt cotton -- that
provide habitat for non-resistant bollworm that can mate with
the rare, highly resistant bollworm that survive the high Bt
dose, thereby diluting resistance.
In the first year of commercialization, dramatic evidence --
in the form of failures to control cotton bollworms -- has
emerged. This evidence indicates that Bt cotton does not
produce high enough doses of Bt to delay resistance in the
cotton bollworm. Other evidence indicates the Bt corn does
not produce a season-long high dose against the European corn
borer. (These crops, however, still work well enough to
produce satisfactory control for most farmers).
Since this past summer's failure, Monsanto is suggesting that
a high dose is not needed for the bollworm, and that refuges
alone are sufficient to delay resistance. This assertion
amounts to a new resistance management plan for Bt cotton and
the cotton bollworm. No submission to EPA by Monsanto
detailing a resistance management plan based solely on
refuges has been made available to the public. Nor has EPA
evaluated any refuge-only plans, according to the Union of
Concerned Scientists (UCS).
UCS maintains that EPA has taken a lackadaisical approach to
protecting Bt. After the bollworm problem arose last summer,
UCS urged the Agency to prepare a report on the implications
of the bollworm failure for resistance management in Bt
cotton and to convene a meeting of the Scientific Advisory
Panel to aid in the evaluation. Unfortunately, the Agency has
done neither and it is now too late to complete a
reevaluation and enact changes before farmers plant cotton
this spring.
EPA needs support to strengthen and enforce its requirements
that Bt crops be grown in ways that will delay resistance.
The sustainable agriculture community has a lot at stake. If
insects evolve resistance to Bt in transgenic crops, they
will also be resistant to Bt sprays upon which many organic
and sustainable farmers and IPM practitioners rely.
*** What you can do
In preparation for the March 21 hearing, the Agency is
soliciting comments from the public regarding the
implications for resistance management of the bollworm
control failure; whether resistance management plans should
be mandatory or voluntary; and what scientific data are
needed to evaluate these plans. In addition, EPA is seeking
comments about criteria to be used to determine whether a
pesticide is a "public good."
The biotechnology/pesticide industry and other proponents of
the technology will likely be at the hearing to highlight the
fact that Bt crops work most of the time and to distract
attention from the resistance issue.
Please write to EPA emphasizing that Bt is important to the
organic, sustainable agriculture and IPM communities and that
Monsanto should not determine the life span of Bt's
usefulness.
*** Urge the Agency to:
1) Suspend current registrations and forego future approvals
of Bt crops until workable resistance management plans are
available;
2) Convene a meeting of the Scientific Advisory Panel to
evaluate the current management plans;
3) Make resistance management plans mandatory because
voluntary plans have not worked well in the past.
Send comments, identified with the docket control number OPP-
00470, to arrive before or on March 21.
By mail to:
Public Response and Program Resources Branch, Field
Operations Division (7506C), OPP/EPA, 401 M St., SW,
Washington, DC 20460
By email to:
opp-docket@epamail.epa.gov
(ASCII file with no special characters or encryption)
Source/contact: Jane Rissler, Ph.D., Senior Staff Scientist,
Union of Concerned Scientists, 1616 P St., NW, Washington, DC
20036; phone (202) 332-0900; fax (202) 332-0905.
For an in-depth update on Bt cotton, see "Bt Cotton --
Another Magic Bullet?" by Jane Rissler, in the March 1997
Global Pesticide Campaigner. Contact PANNA for further
information.
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